Revolut and OpenReserve receive preliminary US banking approvals

The OCC has granted preliminary conditional national bank charters to fintech giant Revolut and Andreessen Horowitz-backed startup OpenReserve. Both firms plan to offer blockchain-native services, including digital asset custody and stablecoins. However, neither bank can accept deposits or launch operations until they secure FDIC insurance and Federal Reserve approvals. The decisions align with OCC chief Jonathan Gould's policy of providing regulatory pathways for crypto firms, a trend that continues to draw scrutiny from lawmakers like Senator Elizabeth Warren.

OCC conditional bank approvals

• ▪OpenReserve must raise at least $210 million in initial paid-in capital and maintain a Tier 1 leverage ratio of at least 12% during its first three years of operation
• ▪The Office of the Comptroller of the Currency granted preliminary conditional approval to Revolut to establish a proposed national bank in Connecticut
• ▪Revolut Bank US, N.A. plans to establish its proposed bank in Stamford, Connecticut, with approximately $95 million in initial capital and around 160 employees

FDIC insurance requirements

• ▪OpenReserve must satisfy preopening requirements, obtain Federal Deposit Insurance Corporation deposit insurance, and apply for Federal Reserve Bank stock before commencing operations
• ▪Revolut cannot accept deposits or commence operations until it secures Federal Deposit Insurance Corporation deposit insurance, Federal Reserve approval, and final Office of the Comptroller of the Currency approval
• ▪Revolut plans to launch its proposed national bank in the first half of 2027, representing a timeline of more than a year from its September 2026 preliminary approval

Stablecoin issuance plans

• ▪OpenReserve plans to establish a wholly owned subsidiary to issue, custody, convert, and pay U.S. dollar-denominated reserve-backed stablecoins, though it has not yet filed an application for the subsidiary
• ▪Payment stablecoins in the United States are subject to the GENIUS Act, signed into law in July 2025, which limits issuance to permitted issuers and grants the Office of the Comptroller of the Currency authority over reserves, redemptions, audits, and custody
• ▪Revolut plans to offer Revolut-branded stablecoins issued by a third party, though the company has not yet identified the currency, network, or reserve setup

Blockchain-native banking services

• ▪Revolut currently serves American customers through a partnership with Lead Bank, an FDIC member, but seeks its own charter to hold deposits directly and lower operational costs
• ▪OpenReserve, founded in 2025 by Diwakar Choubey and Richard Correia, raised a $25 million seed round led by Andreessen Horowitz's a16z crypto to build a blockchain-native bank
• ▪OpenReserve plans to operate a digital-only bank with no physical branches, offering deposits, lending, payments, tokenized deposits, and digital asset custody on blockchain rails

Jonathan Gould policy shift

• ▪Since 2025, the Office of the Comptroller of the Currency has received 40 de novo charter applications, approving 21 and denying two
• ▪The Office of the Comptroller of the Currency has granted conditional approvals to crypto-focused firms including Coinbase, Paxos, BitGo, Ripple, Circle, and World Liberty Financial
• ▪In May 2026, Senator Elizabeth Warren criticized the Office of the Comptroller of the Currency for granting national trust charters to crypto firms, accusing them of seeking to operate beyond permitted activities
• ▪Office of the Comptroller of the Currency chief Jonathan Gould has advocated that entities engaging in crypto and novel technologies should have a pathway to become federally supervised banks

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